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What You Need to Know about the New COVID Funding Reporting Requirements

December 30, 2020

Attention COVID-19 funding recipients…the Office of Management and Budget (OMB) has just released the final addendum to the 2020 OMB Compliance Supplement, which could significantly impact your audit requirements.

Did your company receive COVID-19 related funding? On December 22, 2020, the Office of Management and Budget (OMB) released a final addendum to the 2020 Compliance Supplement. The addendum includes new sections for certain COVID-19 programs, changes to several existing programs affected by the pandemic, and other new guidance. Some of the guidance in the addendum could significantly impact your 2020 audit and reporting requirements; here are the key changes you need to know.

Some helpful background

Check out our blog, Did Your Organization Receive COVID-19 Related Funding? Here's What You Should Know. Essentially, if you received funding related to COVID-19, you may need a single audit. Our blog explains the basics of single audits and how to determine if you need one.

3-Month Audit Extension

Recipients and subrecipients of COVID-19 funding with original audit due dates from October 31, 2020 through June 30, 2021 (years ending January 31, 2020 through September 30, 2020) will be allowed a 3-month extension. No extension is permitted for those entities that did not receive COVID-19 funding.

New Programs and Changes to Existing Programs

Eight new COVID-19 programs are included in the addendum, including the Coronavirus Relief Fund (CRF), Education Stabilization Fund and the Provider Relief Fund. The addendum also includes updates to existing programs that have been impacted by COVID.

Provider Relief Funds (PRF)

The addendum notes that 2020 PRF funds used (expenditures and lost revenue) will not be included on the Schedule of Expenditures of Federal Awards (SEFA) for year-ends prior to December 31, 2020. PRF funds should be included in 12/31/20 and subsequent year-ends.

New Compliance Requirement Related to Reporting

For all COVID-19 programs (excluding CRF) addressed in the addendum, organizations must meet the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements. FFATA applies to all recipients of federal funding who have subawards of $25,000 or more. This requirement will be effective immediately for COVID-19 programs and will be extended to all major programs, regardless of whether COVID-19 funding is involved, for federal audits with fiscal year-ends after September 30, 2020.

Donated PPE to be Reported on SEFA

As part of the COVID-19 response, federal agencies and federal award recipients donated personal protective equipment (PPE) to non-federal entities. Non-federal entities that received donated PPE should disclose the fair value of that PPE at the time of receipt in a separate footnote on the SEFA. This amount will not be audited at the recipient level and should not be included with federal expenditures in the recipient’s SEFA.

Contact us for further guidance.

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